Legal Opinion
Crescent Holdings LLC, Arthur W. & Joleen H. Fields, A Partner Other Than the Tax Matters Partner v. Commissioner
United States Tax Court
Decided December 2, 2013No. 23756-11, 23757-11Published
1Opinion of the Court
141 T.C. No. 15
UNITED STATES TAX COURT CRESCENT HOLDINGS, LLC, ARTHUR W. FIELDS AND JOLEEN H. FIELDS, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 23756-11, 23757-11. Filed December 2, 2013. Holdings was a limited liability company formed on Sept. 7, 2006, and classified as a partnership for Federal income tax purposes. Resources was a limited liability company whose ownership was transferred to Holdings on Sept. 7, 2006. On Sept. 7, 2006, Resources entered into an employment agreement with P to have Holdings transfer a…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. BlissSupreme Court of the United States · 1934
- Blonien v. Comm'rUnited States Tax Court · 2002
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Lawrence J. Alves and Myra L. Alves v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
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